AML & KYC Policy
Our Anti-Money Laundering and Know Your Customer framework, built in compliance with Nigerian law, FATF recommendations, and international sanctions standards.
1. Overview & Commitment
Sovereign AI is committed to maintaining the highest standards in Anti-Money Laundering (AML) compliance and Know Your Customer (KYC) verification.
This Policy establishes our framework for detecting, preventing, and reporting financial crimes, money laundering, terrorist financing, and fraud.
All Members, affiliates, and Hardware Program investors are subject to this Policy.
2. Regulatory Framework
Our AML/KYC framework is designed in compliance with: The Money Laundering (Prevention and Prohibition) Act 2022 (Nigeria).
The Financial Action Task Force (FATF) Recommendations.
The Economic and Financial Crimes Commission (EFCC) Act.
Central Bank of Nigeria (CBN) AML/CFT Regulations.
The Terrorism (Prevention and Prohibition) Act 2022 (Nigeria).
To the extent applicable, EU Anti-Money Laundering Directives (AMLD) for EU-resident Members.
3. Customer Due Diligence (CDD)
Standard CDD (All Members): Verification of full name, email address, and phone number upon registration.
Enhanced CDD (Hardware Program Investors & Seed Holders): Government-issued photo ID (National ID, International Passport, or Driver's Licence).
Proof of address (utility bill or bank statement, no older than 3 months).
Source of funds declaration for investments above ₦1,000,000 or $2,500 USD equivalent.
BioVault KYC: Our optional FIDO2 passkey registration provides biometric authentication without storing raw biometric images, offering passwordless enhanced security for high-value accounts.
Ongoing Monitoring: Member transaction patterns are continuously monitored for anomalies consistent with money laundering indicators.
4. Risk-Based Approach
We categorise Members into three risk tiers: Low Risk — Standard Members with verified identity, normal transaction patterns, and no adverse media.
Standard CDD applies.
Medium Risk — Members in higher-risk jurisdictions, those conducting multiple large transactions, or those with inconsistent source-of-funds information.
Enhanced monitoring applies.
High Risk / PEP — Politically Exposed Persons (PEPs) and their associates are subject to Enhanced Due Diligence (EDD) including senior management approval before onboarding.
We may decline to onboard or transact with high-risk individuals at our sole discretion.
5. Prohibited Activities
The following are strictly prohibited on the Platform: Registering using false or impersonated identity.
Making payments from accounts not in the Member's name.
Structuring transactions to evade reporting thresholds (smurfing).
Use of Platform services to launder proceeds of crime.
Funding by sanctioned individuals, entities, or jurisdictions (OFAC, EU, UN sanctions lists).
Any transaction with a nexus to terrorist financing or proliferation financing.
6. Suspicious Activity Reporting
We file Suspicious Activity Reports (SARs) with the Nigerian Financial Intelligence Unit (NFIU) where we have reasonable grounds to suspect that a transaction is connected to money laundering, fraud, or terrorism financing.
Our compliance team conducts internal suspicious transaction reviews within 24 hours of detection.
Tipping off a subject of a SAR is prohibited by law and will not occur.
7. Sanctions Screening
All new Members are screened against OFAC (SDN List), EU Consolidated Sanctions List, UN Security Council Consolidated List, and HMT UK Sanctions List at the time of registration and on an ongoing basis.
Any positive match results in immediate account suspension and reporting to applicable authorities.
We do not knowingly onboard individuals from sanctioned countries.
8. Record-Keeping
All KYC documentation, transaction records, and SAR filings are retained for a minimum of 7 years from the date of the relevant transaction or relationship termination, as required by Nigerian law.
Records are stored in encrypted form and accessible only to authorised compliance personnel.
Our tamper-evident audit trail system ensures the integrity of all compliance records.
9. Contact & Reporting
To report suspected financial crime or ask compliance questions: Email: compliance@drpcoa.com.
For anonymous tip-offs, you may contact the EFCC at efcc.gov.ng or the NFIU at nfiu.gov.ng.
This Policy was last reviewed on 21 August 2026 and is subject to annual review.